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    <title>2024 (8) TMI 276 - ITAT CHENNAI</title>
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    <description>ITAT Chennai allowed the assessee&#039;s appeals across multiple assessment years (2011-16) regarding TDS disallowances under section 40(a)(i). The tribunal held that payments to German professionals Eva Delith and BDO Deutsche Warentreuhand were not taxable in India as they had no permanent establishment or fixed base in India, thus no TDS deduction was required. Similarly, segregation charges paid to non-residents for warehousing services in Germany, payments to Japanese Scientists and Engineers for Deming Prize advertisement, and market research expenses paid to US entity were allowed as these services were rendered outside India without permanent establishment. CSR expenditures were allowed as revenue expenses for assessment years prior to 2015-16 amendment. Interest-free advances and section 80G claims were remitted back to AO for verification.</description>
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      <description>ITAT Chennai allowed the assessee&#039;s appeals across multiple assessment years (2011-16) regarding TDS disallowances under section 40(a)(i). The tribunal held that payments to German professionals Eva Delith and BDO Deutsche Warentreuhand were not taxable in India as they had no permanent establishment or fixed base in India, thus no TDS deduction was required. Similarly, segregation charges paid to non-residents for warehousing services in Germany, payments to Japanese Scientists and Engineers for Deming Prize advertisement, and market research expenses paid to US entity were allowed as these services were rendered outside India without permanent establishment. CSR expenditures were allowed as revenue expenses for assessment years prior to 2015-16 amendment. Interest-free advances and section 80G claims were remitted back to AO for verification.</description>
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